Armstrong 1: Correspondence

LAW OFFICES OF

BARRETT S. LITT

THE OV1ATT BUILDING
617 SOUTH OLIVE STREET, SUITE 1000
LOS ANGELES, CALIFORNIA 90014
TELEPHONE: (213) 623-7511

August 11, 1983
Jolene Young

Feldsott, Lee and Van Gemert
1617 West Cliff Drive, Suite 204
Newport Beach, California 92660

Re: Depositions in the case of Church of Scientology v. Gerald

Armstrong , No. C 420 153

Dear Ms. Young:

This office represents Mary Sue Hubbard, plaintiff in intervention
in the case noted above. As I believe you are aware, you have
been identified by either Gerald or Joyce Armstrong as one of the
individuals they have talked to about the above-mentioned case.

We are, therefore, interested in taking your deposition at the
earliest practicable date. We do not wish, however, to incon¬
venience you, or the other employees at this office who may also
have information relevant to this proceeding. In order to avoid
such inconvenience, I would suggest adopting the following proce¬
dure: (1) If you contact me by telephone as soon as possible we

can discuss informally the substance of your anticipated deposi¬
tion testimony. On that basis we may conclude that actually
taking your deposition will be unnecessary. (2) If your deposi¬
tion is necessary, I'm willing to schedule it in your office at a
mutually convenient time.

I had previously explained to Julia Dragojevic, attorney for Mr.
Armstrong, that, in order to avoid any unnecessary inconvenience
to you, we were prepared to follow the above procedure. She in¬
dicated that no such approach was agreeable to you. Please under¬
stand that our proposal is done as a courtesy to you. We are, of
course, prepared to proceed by way of deposition. You may feel
that you have no place as a witness in this lawsuit, and you may
be right. However, we believe it is necessary to pursue informa¬
tion you may have, and we hope you understand why, from our point
of view, it is necessary. Obviously, we cannot reach a conclusion
on whether you have any pertinent information until we have the
opportunity to interview or depose you.

I am sending this identical letter to the following people,
including yourself: Michael Walton, Barbara Murray, Stanley
Feldsott, and Jolene Young. In the event that it is necessary to

✓

BARRETT S. LITT
MICHAEL S. MAGNUSON
CARLA BARBOZA

200

August 12, 1983
Ms. Young
Page 2

schedule depositions, I would like to set them on the same day.
In the event you wish to cooperate in this matter, please try to
coordinate among yourselves regarding the dates on which you are
available.

I would appreciate a response to this letter either by telephone
or in writing within five days of its receipt. If I do not
receive such a response, I will schedule these depositions at my
convenience and arrange for service of the necessary subpoenas.

I appreciate your courtesy and cooperation regarding this matter

Very truly yours,

cc: Julia Dragojevic